HomeMy Public PortalAbout2005.12.04 Asphalt Pollution Petition12/05/05 15:11 2Y2089750504
04/09/2004 08:29 FAX 2090730287
STATE OF IDAHO
DEPARTMENT OF
ENVIRONMENTAL QUALITY
DEO BOISE REGION _ 1j001
DEQ GOI,8E REGIONAL g 001/001
t 4a31MoAff Orchard • Boise, Idaho 897064238 - ROM 873.0550 Dark Kernottrme, Governor
C. Stephen Allred, Director
TRANSMITTAL COVER SHEET
Boise Regional. Office
1445 N. Orchard Street
Boise, Idaho 83706-2239
Phone: (208) 373-0550
Fax: (208) 373-0287
DATE: ILth
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12/05/03 15:11 172083730504
DEQ BOISE REGION
a 002
GENERAL INFORMATION
Evaluation Type:
❑ PCE
"Other.
INSPECTION REPORT
FORM ACM
❑ FCE Component ® Investigation Component
Facility Name: Valley Paving and Asphalt
Facility Address: P. O. Box 57, Cottonwood ID, 83522
Facility Location: McCall
Facility ID No. (AIRS No.) 777-00086
Facility Contact: Chris Seubert Pit: 962-3314 Fa::
Permit No.:
777-0008B
Source Class: El B ► � SM ❑ SM80 ❑ A ❑ Mega ND
Date Inspection Commenced: October 19.2005
Inspection Performed By: Tom Anderson
Operating Status During Inspection:
Overall Compliance Status:
Program Office Copies:
Permit Coordinator
Enforcement Coordinator
Date Entry
El °Mang
❑ Temporarily Not Operating
❑ Permanently Closed
❑ In
Out
❑ Pending
►_74
FORM AO.C7 (8272003) Page _ of _
12/05/05 15:12 272083730504
DEQ BOISE REGION
10 003
INSPECTION REPORT
FORM IH]-C7
Applicable Requirements:
Permit Attached (FCE only) [] See Permit in Source File (FCE only)
See attached inspection report.
Inventory $ Descdption of Regulated Emissions Units R Processes:
D Permit Attached (FCE only) ❑ See Permit in Source File (FCC only)
See attached inspection report.
Previous Enforcement Actions: (FCE only)
No current actions.
Preliminary Inspection Findings: PIFF Attached
Comments:
This inspection occurred as a result of odor complaints received by the Boise Regional Office. The
inspection revealed the following permit violations:
Condition 2.2- The facility is using water instead of an environmentally safe chemical soil stabilizer.
Condition 3.22- The scrubber water flow rate monitor is not calibrated annually.
Condition 3.5- Concerning fugitive dust control, no documentation of the frequency of applications per day
of operation or the amount applied per day of operation is available_
Condition 4.1- The facility exceeded the 200 tph asphalt production
2004/2005: 6/4/04- 209 tph 7/20/05- 281.67 tph
W10/04- 239.05 tph 7/21/05- 235.38 tph
M/05- 210.85 tph 9/1/05- 217.05 tph
7/18/05- 204.83 tph 9/2/05- 226.33 tph
Condition 4.3- The plant used No. 2 fuel oil (diesel) until they began blending the diesel with recycled fuel
oil in July of 2005. They were using recycled fuel oil only to fire the asphalt plant at the time Otis
inspection.
limit on the following days during
9/21/05- 251.07 tph
9/23/05- 223.92 tph
9/20/05-.200.45 tph
Conditon 4.6- The facility uses water instead of an environmentally safe chemical soil stabilizer to control
fugitive dust from haul roads.
Condition 5.6- The facility uses water instead of an environmentally safe chemical soil stabilizer to control
fugitive dust from haul roads.
FORM AQ-C7 (0/27/2003)
Page _of_
12/05/05 15:12 122083730504 DEO BOISE REGION
ITh 004
Valley Paving and Asphalt Air Quality Inspection Report
October 19, 2005
Introduction
I arrived at the Valley Paving and Asphalt facility, located on Boydstun St., about 1 mile west of the
intersection of Hwy 55 and Deinhard Ln. in McCall, at approximately 11:00 a.m on October19; 2005. I
introduced myself to Mr. Chris Seubert, Vice President of Valley Paving and Asphalt. Mr. Seubert
checked my credentials and escorted me to his office. I then proceeded to explain the purpose of the
inspection was to dctennine Valley Paving and Asphalts compliance status in regards to their Permit to
Construct (PTC) issued on June 10,1993 and the Mules for the Control of Air Pollution in Idaho.
Mr. Seubert escorted me through the process and we inspected the air emissions sources. The hot -mix
asphalt plant was in operation. The asphalt plant was producing 189 tons per hour (What -mix asphalt
during the inspection. The pressure drop across the wet scrubber was 11" w.c. and the water Row meter
was not installed (see permit condition 3.2). Mr_ Seubert informed me that the plant was using "recycled
fuel oil to fire the bunter. They had begun using this fuel in combination with No. 2 distillate fuel in
July of 2005. Following the inspection of the emission sources, I performed a review of records
pertaining to requirements contained within the valley Paving and Asphalt PTC. None of the records for
calendar year 2004, and portions ate required recordlceeping for calendar year 2005 were located at the
facility. Mr. Seibert informed me that these records d were located at the company headquarters in
Cottonwood I asked that copies of the required records be sent to me by November 2, 2005. The records
were received on November 4, 2005.
On October 24, 2005, I accompanied Mike Spottier and Scott Pitzer to the Valley Paving and Asphalt
plant. The purpose of the visit was to sample the recycled fuel oil tank to verify theanalysis provided
during the October 19 .inspection. DEQ analysis showed that the material sampled meets all applicable
hazardous waste requirements for used oil, therefore it is not a hazardous waste.
1. PROCESS DESCRIPTION
Aggregate, sand, and asphalt chips arc transported on site by truck and placed in piles near the asphalt
plant. Aggregate is loaded via a front-end loader into a 3-bin hopper. This hopper feeds aggregate, sand,
and asphalt chips to a subsequent conveyor belt. The conveyor feeds the burner of a 70 mmBT11 per hour,
No.2 fuel oil -fired Hauck Manufacturing Model SJ360 hot mix drum mixer rated, for a maximum of 200
tons per hour of hot -mix asphalt produced. Heated asphalt oil from a 15,000 gallon portable storage tank
is introduced at the middle of the drum unit, where it mixes with the raw aggregate. The product is then
conveyed to a storage silo via an enclosed slat conveyor. From the silo, the product is transferred by
gravity flow to haul trucks which transport the material .offsite. Emissions front the asphalt drum mixer
are vented to an ABSCO venturi wet scrubber before being emitted to the atmosphere, and operates at a
water flow rate of 60 to 140 gallons per minute and a pressure drop of 12 to 15 inches of water. The
estimated collection Lion efficiency of the scrubber is 9$ percent for control of particulate matter. The fuel for
the planet is stored in two 8,000 gallon tanks, one each for No. 2 fuel oil and recycled fuel oil.
12/05/05 15:15 132083730504
DEQ BOISE REGION Qh005
' 2. EMISSION LIMITS
2.1 Drum Mix Asphalt Plant Stack
2.L 1 Particulate Matter (PM) emissions shall not exceed 0.04 grains per dry standard Cubic feet
as required in 40 CFR Part 60, Subpart I. Nor shall these emissions exceed the pound per
hour (lb/hr) or ton per year (ton/yr) values listed in Appendix A.
COMPLIANCE NOT DETERMINED DURING THIS INSPECTION
2. I.2 Emissions of PM-10 (IDAPA 16.01.01003.73 Rules and Resulatinns_for the Control of Air
Pollution in Idaho).. sulfur dioxide (S02)1oxides of nitrogen (NOx) , volatile organic
compound (VOC) and carbon monoxide (CO) shall not exceed the lb/hr or ton/yr values
listed in Appendix A.
COMPLIANCE NOT DETERMINED DURING THIS INSPECTION
2.1.3 Visible emissions from the asphalt plant scrubber stack shall not exceed twenty (20)
percent opacity for a period or periods aggregating more than three (3) minutes in any
sixty (60) mmute period as required in 40 CFR Part 60, Subpart I, and in IDAPA
16.01.01201. Opacity shall be determined using the Department's "Procedures Manual
for Air Pollution Control".
No visible emissions were seen from the scrubber during the inspection. IN
COMPLIANCE
2.2 Fueitive Emissions
Fugitive missions resulting from the operation of the hot mix asphalt process and associated
aggregate handling shall Abe reasonably controlled in accordance with IDAPA 16.01.01251,
16.01.01252 and 16_01.01605. Haul road fugitive emissions shall be controlled by application of
an environmentally safe chemical soil stabilizer.
Valley Paving and Asphalt is using water to control fugitive dust on the haul roads instead of an
environmentally safe chemical goal stabilizer. OUT OF COMPLIANCE:
2.1 Asphalt Oil gage Tank
Visible emissions from the asphalt oil storage tank shall not exceed twenty (20) percent opacity
for a period Or periods aggregating more than, three (3) minutes in any sixty (60) minute period
as required in IDAPA 16.01. 01201. Opacity shall be determined using the Department's
"Procedures Manual for Air Pollution Control."
No visible emissions were seen from the asphalt oil storage tank during this inspection. IN
COMPLIANCE
2.4 Sulfur Content of Fuel
The sulfur content of the No.2 fuel oil shall not exceed 0.5 percent by weight as required.. by
IDAPA 16.01.01354.02.
The sulfur content of the No. 2 fuel on -site was 0.05% by weight however the hot -mix plant was
combusting recycled fuel oil at the time of this inspection. The sulfur content ofthe .recycled fuel
oil was documented to be less. than. 0.5% by weight. IN COMPLIANCE
12/05/05 15:13 MO53730504 DEQ BOISE REGION
� 006
3.0 ONIT G E UIRENIE S
3.1 The permittee shall install, calibrate, maintain, and operate a monitoring device for the continuous
measurement of the change in pressure across the venturi scrubber throat.
A continuous pressure drop monitor is installed. It was reading 11 "w.c. during this inspection. /N
COMPLIANCE
3. I.1 The change in pressure across the venturi scrubber throat shall be recorded at least once
per week while the asphalt plant is operating at a normal capacity.
The pressure drop across the venturi scrubber throat is recorded daily. The readings
have been recorded as 11-12 inches of water column in 2004 and 2005. IN
COMPLIANCE
3.1.2 The monitoring device shall be certified by the manufacturer to be accurate within + 1
inch water gauge pressure, and shall be calibrated on an annual basis in accordance with
the manufacturer's instrue6ons.
The pressure drop monitoring device is calibrated every year. IN COMPLIANCE .
3.1.3 Maintenance to the venturi scrubber shall be performed if the visible emissions from the
stack exceed ten (10) percent opacity for a period or periods aggregating more than three
(3) minutes in any sixty (60) minute period.
No documented visible emissions have been seen therefore, no maintenance has ever been
performed due to excess visible emissions. NOT APPLICABLE AT THE TIME ow
THIS INSPECTION
3.2 The pemittee shall install, calibrate, maintain, and operate a monitoring device for the
continuous measurement of the scrubbing water flow rate to the venturi scrubber throat.
3.2.1 The scrubber water flow rate shallbe recorded at least once per week white the asphalt
plant is operatingat a normal capacity.
The permittee has a portable flow rate monitor. I was informed by Mr. Seubert that the
monitor is installed once per week to get a flow rate reading. The recordkeepiug
documentation submitted by Valley Paving and Asphalt on Novvember4, 2005, lists a
flow rate of 112 gallons per minute for each day of operation in 2004 and 2005
including the date of this inspection. The flow rate monitor was observed lying by an
equipment trailer during this inspections, No flow rate monitoring was conducted durin
this inspection. COMPLIANCE NOT DETERMINED S
3.2.2 The monitoring device shall be certified by the manufacturer to be accurate + five (5)
percent of the actual scrubbing water floor ram, and must be calibrated on an annual
basis in accords with the manufacturer's instructions.
Ms: Seibert stated that this monitor is not calibrated annually. OUT OF
COMPLIANCE
3.3 The permittee shall conduct a performance test to measure particulate matter emissions from the
asphalt plant venturi scrubber stack in accordance with 40 CFR Part 60, Subpart I, the
Department's "Procedures Manual for Air Pollution Control", and General Provision F of this
permit. Visible emissions shall be observed during this test using the methods in the
Department's "Procedures Manual for Air Pollution Control".
The performance test was conducted on August 20,1993, and the test report was received on
September 20,1993. The results were approved by DEQ on December 2,1994. IN
COMPLIANCE
3A During the performance test required in section 3.2, the following data shall be monitored and
recorded:
3.4.1 Process weight rate (i.e., tons of asphalt produced per hour).
3.4.2 Burner fuel Bow rate (i.e., gallons per bout).
3A.3 Fuel oil sulfur content (i.e., percent by weight).
3.4A Change in pressure across the venturi scrubber (i.e., inches of water).
3.4.5 Water flow rate through the venturi scrubber (i.e., gallons per minute).
During the August 20,1993, test the plant averaged 201.1 tons per hour of asphalt produced, a
burner fuel flow rate of 300 gallons per hour, a fuel oil sulfur oil content of 0.05 percent by
weight, ,a pressure drop across the venttu'i scrubber of 11" w.c.,. and a water flow rate through the
venturi scrubber of 110 gallons per minute. IN CO1V[PLIANCE
3.5 The permittee shall record the following information concerning fugitive dust control: .
3.5.1 Type of control used.
3.5.2 Frequency of applications per day of operation.
3.5.3 Amount applied per day of operation.
Valley Paving and Asphalt stated in the recordkeeping submitted on November 4, 2005, that all
haul roads are watered on a daily basis or more often as required. They are not monitoring this
infomiation on a daily basis, as no documentation of the frequency of applications per day or
the amount applied per day of operation is available. OUT OF COMPLIANCE
4. OPERATING REQUIREMENTS
4.1 Production Limit
The maximum hourly production rate shall not exceed 200 tons of asphalt concrete per hour.
The maximum annual. production race shall not exceed 280,000 Mons of asphalt concrete per
year, as per the applicant's submittal.
Valley Paving and Asphalt monitors hourly production by dividing the hours operated each day
by the total amount of asphalt produced. Based on these calculations, Valley Paving and.
Asphalt exceeded the 2oa ton per hour (tph) production rate limit onthe following- dates in 2004
and 2005:
12/05/05 15:14 732083730504
DEO BOISE REGION
Zoos
6/4/04- 209 tph
9/10/04- 239.05 tph
7/7/05- 210.85 tph
7/18/05- 204.83 tph
OUT OF COMPLIANCE
7/20/05- 281.67 tph
7/21/05- 235.38 tph
9/1/05- 217.05 tph
9/2/05- 226.33 tph
9/21/05- 251.07 tph
9/23/05- 223.92 tph
9/29/05- 200.45 tph
The total amount of asphalt produced in 2004 was 37,165.72 tons. The total amount of asphalt
produced thru October 22, 2005 is 96,553.65 tons. IN COMPLIANCE
4.2 Operating Hours
The maximum operating hours for the asphalt plant shall not ecceed 1400 hours per year as per
the applicant's submittal.
The total hours operated in 2004 were 438.37. The total hours operated thru October 22, 2005
is 712.95. IN COMPLIANCE
4.3 FueI Types
The drum -minx asphalt plant may be fired by No. 2 fuel oil.
The plant used No. 2 fuel oil (diesel) until they began blending the diesel with recycled fuel oil
in July of 2005. They were using recycled fuel oil only to dire the asphalt plant at the time of
this inspection. OUT OF COMPLIANCE
4.4 Control Equipment
The venturi scrubber shall be operated at all times during the operation of the drum dryer.
The venturi scrubber was in operation at the time of this inspection. Rocordkeeping shows that
the scrubber is operated whenever the dnun dryer is in operation. IN COMPLIANCE
4.5 Pressure Drop Across Venturi Scrubber
The pressure drop across the venturi scrubber shall not vary more than + thirty (30) percent
from those values recorded during the most recent performance test.
The pressure drop varies less that 10 percent of the values recorded during the most recent
performance test. IN COMPLIANCE
4_6 Fugitive Dust Control
The haul road fugitive emissions shall be controlled by an environmentally safe chemical soil
stabilizer.
Valley Paving and Asphalt uses water instead of an environmentally safe chemical soil
stabilizer to control fugitive dust 8vom haul roads. OUT OF COMPLIANCE
4.7 Suspension of Querations
Operation of the hot asphalt plant must cease during any Air Stagnation Advisories when
operating in nonattaimnent areas.
COMPLIANCE NOT DETERMINED DURING THIS INSPECTION
U
12/05/05 15:15 122083730504 DEO BOISE REGION
fdj 009
4.8 Plant Stack
The minimum distance of the location of any piece of the asphalt plant's equipment from any
property boundary shall be 140 feet.
COMPLIANCE NOT DETERMINED DURING THIS INSPECTION
5. REPORTING REQUIREMENTS
5.1 The permittcc shall submit a test protocol for the performance test required in Section 3.3 of the
permit to the Department for approval at least thirty (30) days prior to each test date.
A performance test protocol was submitted on July 8,1993. The protocol was not reviewed or
approved by DEQ prior to testing. IN COMPLIANCE
5.2 The permittee shall submit a written report of the asphalt plant venturi scrubber performance
test to the Department and EPA within thirty (30) days of performing the test. In addition,
information as required in Section 3.4 shall be submitted as recorded during each performance
test run.
The performance test was conducted on August 20,1993. The test report was received by DEQ
on September 20,1993. IN COMPLIANCE
5.3 The permittee shall record the hours of operation and the information and monitoring results
addressed in Sections 3.1 and 3.2 of this permit in a monthly report to be on site for a two (2)
year minimum period, and made available to Department representatives upon request.
See Sections 3.1 and 3.2 of this report.
5.4 At least ten (10) days prior to the relocation of any operations pertaining to this permit, the
petmittee shall submit a written report to the Department which addresses:
5.4.1 When start-up will occur and how long operations will last.
5.4.2 Location of planned relocation.
5.43 All equipment and above information shall be registered on relocations forms supplied
by the Department at least ten (10) days prior to relocating.
The asphalt plant had not relocated in 2004 or 2005. NOT APPLICABLE AT THE 'FOIE
OF THIS INSPECTION.
5.5 Special Department approval must be received by the permittee prior to relocating any
operations pertaining to this permit in an area which is designated nonattainmemt for any of the
pollutants in Appendix A.
The asphalt plant had not relocated into a nonattahnnent area.2004 or 2005. NOT
APPLICABLE AT THE TIME OF THIS INSPECTION:.
5.6 All chemical dust suppressants shall be approved by DEQ prior to application of the dust
suePressant.
Valley Paving and Asphalt is using water instead of chemical dust suppressants to control
fugitive dust_ OUT OF COMPLIANCE
12/05/05 15:15 222085750504
DEQ BOISE REGION Z010
Page 1 of 1
Thomas Krinke
From: Michael Spomer
Sent: Wednesday, November 09, 200511:57 AM
To: Thomas Krinke
Subject: FW: Analyticai results from Valley Paving - McCall
attachments: Valley Paving and Asphalt - McCall 10-24-05.xls
Fyi
From: Michael Spomer
Sent: Wednesday, November 09, 200510:38 AM
To: Michael Gregory; Eileen t oerch
Cc: Ron lane; Scott~ Pitzer
Subject: Analytical results from Valley Paving - McCall
Mice and Eileen
Attached is a sumrnary of the lab results of the Recycled Fuel oil sampled on October 24, 2005 at Valley Paving
and Asphalt in McCall.
Based on the results, it does not appear the material is a hazardous waste and is below the limits governing used
oil.
I assume this woukl be the end of the investigation forwaste.
Let me know if you need anything else.
Mike
{ 11/29/2005
DEQ BOISE REGION
272083730504
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12/05/05 15:16 122083730504 DEO BOISE REGION
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lFuet Ong.7336 Coral LLC.
Mesnpq, Id. 63667
Phone,208,465.&296
Fadk205-142 2829
allows at Analysis
SrilP to: VALLEY PAVING AND ASPHALT, McSidi ID
Ship Fmm= Comments Fud ROoy % LLC.
Date eceected: mi3/2005
Date 10/3/2005
Fuel two Ftegole0 Fuel Oil
Sample* 100305-071205-1
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Chromium
Lead
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Total halogens
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6010 .Q,Oppm .
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6010 4700.0ppm
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7
McCall Citizens Against Asphalt Pollution
Lindley Kirkpatrick
City Manager
City of McCall
December 28, 2005
Dear Mr. Kirkpatrick:
We are part of a larger group of citizens of McCall affected by the substantial
airborne pollution emitted by the Valley Paving and Asphalt Company ("Valley Paving")
as part of its asphalt production process. Because of the public health and safety risks
associated with such substantial amounts of airborne pollution, we ask that the City re-
examine the zoning regulations applicable to the plant and take all possible action to
abate the pollution. A petition requesting expedited action from the City Council on this
matter is being circulated among citizens and property owners of McCall.
By way of backgfound, Valley Paving is located at 212 Industrial Loop. The
plant is in close proximity to concentrated residential areas, including the Rio Vista
neighborhood and the Pine Terrace II and Valley View subdivisions. Other new
residences are being constructed to the north, northwest, and west of the plant. The
Industrial hoop area is quickly becoming a pocket within a broader residential area.
The plant emits a Iarge plume as part of its operations, as shown in the attached
photos (Attachment A), as well as fugitive emissions from various locations at the site.
This plume drifts into and over the surrounding residential neighborhoods following the
direction of the wind. The pollution frequently carries a strong, noxious odor and fumes
that cause substantial and'ongoing interference with the use and enjoyment of residential
property. It has become intolerable to many affected property owners: During the past
summer, various homeowners had to stay inside and keep all windows and doors shut to
avoid the pollution and were thus completely prevented from enjoying their yards during
the long summer hours the plant was operating. Mothers pulled their children inside to `
avoid the health effects of the pollution. When the pollution enters the home the
offensive, pungent odors can Iinger for extended periods of time because there is no way
to circulate the home with clean air. The pollution is even further exacerbated during
those times when McCall experiences an air inversion.
Asphalt plants are a cause for significant concern when located near residential
neighborhoods because they typically emit a variety of harmful pollutants, including
volatile organic compounds (VOCs), polycyclic aromatic hydrocarbons (PAHs),
particulate matter, nitrogen oxide, carbon monoxide, and sulfur dioxide. The U.S.
Environmental Protection Agency (EPA) has issued a report, HOT MIX ASPHALT PLANTS:
EMISSIONS ASSESSMENT REPORT, EPA-454/R-00-019 (EPA 2000), which inventories
typical emissions from a typical drum mix asphalt plant. The report is available at
http://www.epa.gov/ttn/chief/ap42/chll/related/ea-reportpdf. See Attachment B
1
mcapmccall@yahoo.com
(report's chart listing hazardous and other regulated air pollutants from asphalt plants).
The carcinogenic and/or other serious health risks associated with these pollutants are
reported in the U.S. Environmental Protection Agency's National Scale Air Toxics
Assessment, available at http://www.epa.gov/ttn/atw/nata/index.html. See also
Attachment C (Ohio Environmental Protection Agency Fact Sheet: Information
Regarding Asphalt Concrete Plants, Nov. 5, 1996), concluding, "Asphalt plants are
regulated because they ... may emit significant levels of both particulate matter and
gaseous volatile organic compounds (VOCs). These pollutants are considered to be
detrimental to human health. Some VOCs are suspected carcinogens."
Because of the unpleasant and toxic airborne pollution they emit, asphalt plants
should not be sited near residential areas. Some cities have enacted full moratoria against
location of asphalt plants. This plant, however, was presumably permitted back in 1993
under McCall's zoning ordinance, although the City has yet to provide citizens with a
particular permit or conditions. At the time the asphalt plant was initially located at the
Industrial Loop site, there was likely very little or no review by the City as to the impacts
on nearby property owners. The Rio Vista neighborhood was already well -established at
that time, and therefore the asphalt plant was not a prior use. Taxpaying property owners
have legitimate, antecedent expectations that they may reasonably enjoy their property
free of the noxious fumes emitted by this plant.
The asphalt plant is regulated by the Idaho Department of Environmental Quality
(DEQ) under the federal Clean Air Act and state regulations, but in 12 years of operation,
it had never been inspected for compliance with the law. On October 19, 2005, pursuant
to persistent complaints about the pollution, the DEQ inspected the plant and found a
major violation. The permit for the plant requires the plant to use No. 2 fuel oil (diesel).
Instead, since July, 2005, the plant had been illegally using recycled fuel oil in its
process. See Attachment D (Inspection Report Summary). Recycled fuel oil can come
from any number of sources and contain a variety of contaminants never contemplated in
the air quality permit. On October 24, 2005, three DEQ officials arrived at the plant to
take a sample of the recycled fuel oil. The sample from the batch on site that day
revealed heavy metals such as chromium, lead and barium, and hazardous chemicals such
as benzene, toluene, ethyl benzene, xylene, and chlorine. See Attachment E (lab report
provided by DEQ). There may have been a host of additional contaminants in the oil that
the DEQ did not test for. Such unpermitted contaminants in the fuel oil can result in an
additional, serious, pollution load for the affected neighborhoods. This constituted a
serious air quality violation, and the case has been referred to the enforcement division of
the DEQ. Some citizens of McCall will be asking DEQ to impose stringent penalties on
the owner and manager of Valley Paving in light of the harm this pollution has caused to
affected residents.
Beyond illegally using recycled fuel oil in violation of the permit, Valley Paving
has increased its production tremendously in the last year. Records provided by the
company to DEQ show that production by October 22, 2005 was nearly triple the entire
production of the prior year. In 2004, the plant produced 37,165 tons of asphalt. By
October 22, 2005, it had produced 96,553 tons. See Attachment F (inspection report). In
past years the plant has shut down for the cold season (approximately mid -November to
2
mcapmccall@yahoo.com
mid -April), thereby affording some relief to property owners in the winter season. In
2005, however, the plant has continued to operate through the cold months of November
and December. The plant has on several occasions illegally exceeded its production
limit in violation of its permit. See Attachment D (Inspection Report Summary). This
increased production delivers a significant additional load of pollution to surrounding
neighborhoods and represents a substantial change in operations.
It is the City's responsibility to ensure appropriate zoning to safeguard the
property rights and health of its landowner citizens. While DEQ regulates the air quality
of the McCall airshed as a whole, it does not take into account harm to residents from
localized air pollution, as the responsibility for appropriate land use regulation lies with
the city. The air quality regulations enforced by the state are not intended to replace
sensible land use zoning regulation, and the Valley Paving permit expressly states it does
not release Valley Paving from compliance with local laws. See Attachment G (Permit #
777-00086). The intolerable pollution emitted from the plant represents a clear nuisance
as defined by the McCall land use code, section 3-27-020(A)(2): "No use shall be
permitted or ... maintained which is or may become:... 2) noxious, or cause offensive
conditions due to emission of odor, dust, smoke, cinders, gas, fumes, noise, vibration,
refuse matter or water -carried wastes."
Conditions have changed since the initial start-up of the plant to make the plant an
incompatible use in violation of the nuisance code on a regular basis. The harmful
impacts of the plant are exponentially greater than when the plant first began operating
because: 1) the pollution from the plant has substantially increased as a result of nearly
tripled (or more) production; 2) the operating timeframe has been extended to seemingly
year-round despite cold temperatures; 3) the illegal use of recycled fuel oil exposes
residents of McCall to a potentially much greater range of harmful pollutants; and 4) the
number of property owners suffering impacts has increased multifold as a result of
development on all sides of the plant. We believe the operation of this plant is now
fundamentally incompatible with the zoning code.
This asphalt plant, like others of its kind, is portable. Asphalt plants are
intentionally designed to be portable to allow relocation closer to the paving jobs. This is
important because the asphalt must be kept hot to ensure proper application; the greater
the distance from the job site, the greater the cooling during transport. Valley Paving's
air quality permit specifically notes that the plant is portable (Attachment G, permit
section 1.3.2) and an accompanying memorandum by the Operating Permits Bureau of
the DEQ states, "Valley Paving is a portable source to be initially located in McCall,
Idaho." (Emphasis added). See Attachment H (memorandum). The permit also has a
"Portable Equipment Registration and Relocation Form" attached to it for the purpose of
facilitating the relocation of the plant. See Attachment I (relocation form). Since the
plant's operation has become a nuisance on a regular basis, we believe it should be
relocated to a more appropriate area away from any residential zones.
We ask the City Council to investigate the land use/zoning status of this plant and
take immediate action to abate the pollution through whatever means is appropriate to
prevent further interference with the property rights and health of its citizens.
3
mcapmccall@yahoo.com
r
We look forward to your response.
7 /0- )n---
G
4
CC:
June Hues
Airshed Manager
Boise Regional Office
Department of Environmental Quality
Michael R. McGown
Administrator
Boise Regional Office
Department of Environmental Quality
Doug Cole
Idaho Air Coordinator
U.S. Environmental Protection Agency
Martin Bauer
Administrator
Air Quality Division
Department of Environmental Quality
Eileen Loerch
Compliance and Enforcement
Enforcement Division
Department of Environmental Quality
5
Addresses:
General assistance: 373-0240
Eileen Loerch
Compliance and Enforcement
Department of Environmental Quality
1410 N. Hilton
Boise, ID 83706
208 373-0469
Martin Bauer
Administrator, Air Quality Division
Department of Environmental Quality
1410 N. Hilton
Boise, ID 83706
208 373-0440
Michael R. McGown
Administrator
Boise Regional Office
Department of Environmental Quality
1445 N. Orchard
Boise, ID 83706
208 373-0550
June Hues
Airshed Manager
Boise Regional Office
Department of Environmental Quality
1445 N. Orchard
Boise, ID 83706
208 373-0550
Doug Cole
Idaho Air Coordinator
U.S. Environmental Protection Agency
1435 N. Orchards St.
Boise, ID 83706
6
United States . Office Of Air _Quality EPA-454SR-00-019
Environmental Protection Planning And Standards December 2000
Agency Research Triangle Park, NC 27711
Air
�ft'i EPA HOT MIX ASPHALT PLANTS
•
EMISSION ASSESSMENT REPORT
OLH- 73 00(3)
TABLE 8. ESTIMATED ANNUAL EMISSIONS FOR
A TYPICAL DRUM MIX DRYERa
Pollutant
No. 2 fuel oil -fired dryer 1 Natural gas -fired dryer
Emissions, lb/yr
Criteria Pollutants
PM 10
4,600
4,600
VOC
6,400
6,400
CO
26,000
26,000
SO,
2,200
680
NO,
11,000
5,200
PAHs (semi -volatile HAPs)
2-Methylnaphthalene
34
15
Acenaphthene
0.28
0.28
Acenaphthylene
4.4
1.7
Anthracene •
0.62
0.044
Benzo(a)anthracene
0.042
0.042
Benzo(a)pyrene
0.0020
0.0020
Benzo(b)fluoranthene
0.020
0.020
Benzo(e)pyrene
0.022
0.022
Benzo(g,h,i)perylene
0.0080
0.0080
Benzo(k)fluoranthene
0.0082 •
0.0082
Chrysene
0.036
0.036
Fluoranthene
0.12
0.12
Fluorene
2.2
0.76
Indeno(1,2,3-cd)pyrene
0.0014
0.0014
Naphthalene
130
18
Perylene ,
0.0018
0.0018
Phenanthrene
4.6
1.5
Pyrene
0.60
0.11
Total PAHs
180
37
Volatile HAPs
Isooctane
8.0
8.0
Hexane
184
180
Benzene
78
78
Ethylbenzene
48
48
Formaldehyde
620
620
Methyl chloroform
9.6
9.6
Toluene
- 580 _
30
Xylene
40
40
Total volatile HAPs
1,568
1,020
Metal HAPs
Lead
3
0.12
Mercury
0.52
0.048
Antimony
0.036
0.036
Arsenic
0.11
0.11
Beryllium
0.000
0.000
Cadmium
0.082
0.082
Chromium
1.1
L 1
Manganese
1.5
1.5
Nickel
12.6.
12.6
Selenium
0.070
0.070
Total metal HAPs
19
16
a Dryer controlled by fabric filter producing 200,000 tons of hot mix asphalt per year. Between 70 and 90 percent
of HMA is produced using natural gas; most of the remaining HMA is produced using fuel oil.
22
TABLE 7. ESTIMATED ANNUAL EMISSIONS FOR TYPICAL
BATCH MIX PLANT ASPHALT STORAGE TANKa
Pollutant
Emissions, lb/yr
Criteria Pollutants
PM-10
ND
VOC
32
CO
3
PAHs (semi -volatile HAPs)
Acenaphthene.
0.0027
Acenaphthylene
0.0010
Anthracene
0.00092
Benzo(b)fluoranthene
0.00051
Fluoranthene
0.00022
Fluorene
0.00016
Naphthalene
0.087
Phenanthrene
0.025
Pyrene
- 0.00016
Total PAHs
0.12
Volatile HAPs
Benzene
0.010
Bromomethane
0.0016
2-Butanone
0.012
Carbon disulfide
0.0051
Chloroethane
0.0012
Chloromethane
0.0074
Ethylbenzene
0.012
Formaldehyde
140
n-Hexane
0.032
Isooctane
0.000099
Methylene chloride
0.000086
Phenol
0.00
Styrene
0.0017
Toluene
0.020
mop-Xylene
0.061
o-Xylene
0.018
Total volatile HAPs
140
a Uncontrolled emissions from plant producing 100,000 tons of hot mix
asphalt per year. Includes emissions from oil -fired hot oil heaters. All
calculated PAH emissions and almost all of the formaldehyde emissions
are from the oil -fired hot oil heater.
21
Asphalt Plants
http://www.epa:State.oh.us/dapc./sba/asp
&WM! Links
► Public Participation
if, Offices & Programs
Small Business
Assistance Office
Division Links
1. Forms lit Publications
► Rules 8 Laws
E-Check
I. Title V
► STARShip
► Permits
► Fee Programs
► Right To Know
► What's New
Print fps
► Home
2Air% Lane ; -ter ;_,Po1lt1#aifPrefrenton •liCinfarmation
►' Asphalt Plants
► Chemical Mfg ► Chrome
Electroplaters
► Autobody and Repair
► Dry Cleaners
► Gas Stations * Laboratories ► Metal Fabricator / Metal
Parts Cleaner
► Printers > Quarry / Sand and * Refrigerator / Air
Gravel Conditioning Service and
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► Bakeries
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Operations
► Wood Products -
Fact Sheet: Information Regarding Asphalt Concrete Plants
Number 5, November 1996 •
Ohio EPA, Division of Air Pollution Control
Small Business Assistance Program
Under state and federal law, operators of hot mix asphalt plants may be required to obtain air
pollution permits from Ohio EPA. It is the responsibility of the plant owner to acquire these
permits. To obtain air pollution permit applications, the plant owner should contact the Ohio
EPA district office or local air agency that handles the area in question. To determine which
office handles your area, call Ohio EPA's Division of Air Pollution Control at (614) 644-2270.
Why are air permits required for these sources?
Asphalt plants are regulated because they are air pollution sources that may emit significant
levels of both particulate matter and gaseous volatile organic compounds (VOCs). These
pollutants are considered to be detrimental to human health. Some VOCs are suspected
carcinogens.
What parts of the asphalt plant emit these pollutants?
The mixer is the most significant ducted source of emissions in an asphalt plant and in most
cases the mbcers will need to be permitted as an air pollution source. The mbcer may be the
source of both particulate emissions and also VOC emissions. Often, a baghouse, cyclone or
other emission control device is required to reduce the particulate emissions from the mixer.
The other sources at a plant that may contribute fugitive emissions of particulate, and
therefore need permitting, indude storage piles, material handling, and roadway and parking
areas.
What kind of requirements will the air pollution permit place upon an asphalt concrete
plant?
Permits for asphalt plants will often require the company to maintain their particulate and VOC
emissions under a prescribed emission limit (in doing so, this may necessitate the company
installing emission control equipment). These limits win usually be given in either pounds per
day or in pounds per hour. To monitor the source's emissions, the permit terms and conditions
may require the company to keep daily or monthly records of their production rates. These
records are to be kept on site and. available for review upon request of Ohio EPA. While the
terms and conditions of a permit are set by Ohio EPA, companies may negotiate these terms
with Ohio EPA before they are established.
Can I get help with my pennit applications?
In Ohio, companies that employ fewer than 100 workers and are not classified as a major
source can receive FREE and CONFIDENTIAL assistance from the Ohio Small Business
Assistance Program (SBAP). The SBAP will tour your fealty lity and help you determine if your
facility needs pemrits. If it is concluded that your facility does need air pollution permits, the
SBAP will assist you in completing the applications. By law, all information SBAP learns during
1- of 2
9/19/05 1:32 PM
12/05/05 15:11 222083730504
DEQ BOISE REGION
lit 002
GENERAL INFORMATION
Evaluation Type:
•
Facility Name:
Facility Address; P. O. Box 57. Cotto►rivo ID. $3522
Facility Location; McCall
INSPECTION REPORT
❑ PCE ❑ FCE Component Ej Investigation Component
ErOther.
Valley Paving and Asphalt
Facility ID No. (AJRS No) 777-00086
Facility Contact: Chris Seubert Phi 962 3314 Fax:
Permit No.: 777-00086
Source Class:
[] B ® SM 0 SM80
Date Inspection Commenced: October 19. 2005
Inspection Performed By: Tom Anderson
Operating Status During Inspection:
Overall Compliance Status:
Program CfRw Copies:
Permit Coorritnator
Enforcement Coordinator
Date Entry
FORM A4C7 (827/2003)
Operating
0 Temporarily Not Operating
❑ Permanently Closed
Din
Out
❑ Pending
►4
Mega ❑ ND
Paso_ of_
15:12 272083730504
v>;e mrulss x> IA MI
r
INSPECTION REPORT
Applicable Requirements:
❑ Permit Attached (FCE only) Ej See Permit in Source File (FCE only)
See attached inspection report.
Inventory cis Description of Regulated Emissions Units & Processes:
D Pewit Attached (FCE only) _Q See Permit in Source File (FCE only)
See attached inspection report.
Previous Enforcement Auctions: (FCE only)
No current actions.
Preliminary Inspection Findings: ® PIFF Attached
Comments:
This inspection occurred as a result of odor complaints received by the Eloise Regional Office. The
inspection revealed the following permit violations:
Condition 22- The facility is using water instead of an environmentally safe chemical soil stabilizer.
Condition 3.22- The scrubber water flow rate monitor is not calibrated annually.
Condition 3.5- Concerning fugitive dust control. no documentation of the frequency of applications per day
of operation or the amount applied per day of operation is available.
Condition 4.1- The facility exceeded the 200 tph asphalt production limit on the following days during
2004/2005: 6/4/04- 209 tph 7/20/05- 281.67 tph 9/21/05- 251.07 tph
9/10/04- 239.05 tph 7/21/05- 235.38 tph 9/23/05- 223.92 tph
7/7/05- 210.85 tph 9/1/05- 217.05 tph 9/20/05- 200.45 tph
7/18/05- 204.83 tph 9/2/05- 226.33 tph
Condition 4.3- The plant used No. 2 fuel oil (diesel) unfit they began blending the diesel wtih recycled fuel
oil in July of 2005. They were using recycled fuel oil only to fire the asphalt plant at the time of this
inspection.
Conditon 46- The facility uses water Instead of an environmentally safe chemical soil stabilizerto control
fugitive dust from haul roads.
Condition 5.6- The facility uses water instead of an environmentally safe theorise! sor7 stabTzrzer to control
fugitive dust from haul roads:
FORM AQ-07 (8/27/2003)
Page _ of_
DEQ BOISE REGION
122083730504
N16u, 841
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The petmittee shall conduct a performance test to measure particulate matter emissions from the
asphalt plant venturi scrubber stack in accordance with.40 CPR Part 60, Subpart 1 the
Department's "Procedures Manual for Air Pollution Control", and General Provision F of this
permit. Visible emissions shall be observed during this test using the methods in the
Department's "Procedures Manual for Air Pollution Control".
Theperformffiuee test was conducted on August 20,1993, and the test report was received on
September 20,1993. The results were approved by DEQ on December 2,1994. IN
COMPLIANCE
3.4 During the performance test required in section 3.2, the following data shall be monitored and
recorded:
' 3A.1 Process weight rate (i.e., tons of asphalt produced per hoot)
3.4.2 Burner fuel flow rate (i.e., gallons per hour)-
3A.3 Fuel oil sulfur content (.e., percent by weight).
3A.4 Change in pressure across the venturi scrubber (i.e., inches of water).
3.4.5 Water flow rate through the verrtmr scrubber (ire., gallons per minute).
During the August 20,1993, test the plant averaged 201.1 tons per hour of asphalt produced, a
burner fuel flow rate of 300 gallons per hour, a fuel oil sulfur oil content of 0.05 percent by
weight, a proms drop across the venturi scrubber of 11" w.c., and a water flow rate through the
venturi scrubber of 110 gallons per minute. 119 COMPLIANCE
3.5 The permittee shall record the following information concerning fugitive dust control:
3.5.1 Type of control used-
3.5.2 Frequency of applications per day of operation.
3.5.3 Amount applied per day of operation.
Valley Paving and Asphalt stated in the recordkeeping submitted on November 4, 2005, that all
not m
haul roads are watered on a daily basis or more often as required. hare nonitoring this
Y per day or
information on a daily basis, as no documentation of the frequency applications �CE P
the amount applied per day of operation is available. OUT OF CO
4. OPERATING REQUMEMENTS
4.1 Production Limit
The maximim hourly production rate shall not eiceed 200 tons of not exceed 2 d,000 tons�of asplualhalt nt�concret per
per hour.
The �hiun annual production rate shall
year, as per the applicant's submittal.
Valley Paving and Asphalt monitors hourly production by dividing the hours operated each day
by the .total amount of asphalt produced- Based on these calculations, Valley Paving and
Asphalt exceeded the 200 ton per hour (tph) production rate limit on the following dates in 2004
and 2005:
i
5:14 02083730504 DEG BOISE REGION
6/4/04- 209 tph 7/20/05- 281.67 tph
9/10/04- 239.05 tph 7/21/05- 235.38 tph
7/7/05- 210.85 tph 9/1/05- 217.05 tph
7/18/05- 204.83 tph 9/2/05- 226.33 tph
OUT OF COMPLIANCE
9/21/05- 251.07 tph
9/23/05- 223.92 tph
9/29/05- 200.45 tph
The total amount of asphalt produced in 2004 was 37,165.72 tons. The total amount of asphalt
produced thru October 22, 2005 is 96.553.65 tons. IN COMPLIANCE
4.2 Operating Hours
The maximum operating hours for the asphalt plant shall not exceed 1400 horns per year as per
the applicant's submittal.
The total hours operated in 2004 were 438.37. The total hours operated thru October 22, 2005
is 712.95. IN
4.3 Fuel Types
The drum mix asphalt plant may be fired by No. 2 fuel oil.
The plant used No. 2 fuel oil (diesel) until they began blending the diesel with recycled fuel oil
in July of 2005. They were using recycled fuel oil only to fire the asphalt plant at the time of
this inspection_ OUT OF COMPLIANCE
4.4 Control Equipment
The venturi scrubber shall be operated at all times during theoperation of the drum dryer.
The venturi scrubber was in operation at the time of this inspection. Rccordkeeping shows that
the scrubber is operated whenever the drum dryer is in operation. IN COMPLIANCE
4.5 Pressure Drop Across Venturi Scrubber
The pressure drop across the venturi scrubber shall not vary more than ± thirty (30) percent
from those values recorded during the most recent performance test.
The pressure drop varies less that 10 percent of the values recorded during the most recent
performance test. IN COMPLIANCE
4_6 Fugitive Dust Control
The haul road fugitive emissions shall be controlled by an enviromnentally safe chemical soil
stabilizer.
Valley Paving and Asphalt uses water instead of an environmentally safe chemical soil
stabilizer to control fugitive dust from haul roads. OUT OF COMPLIANCE
4.7 Suspension of Qperations
Operation of the hot asphalt plant must cease during any Air Stagnation Advisories when
operating in nonattainment areas.
COMPLIANCE NOT DETERMINED DURING THIS INSPECTION
boos
ayc
STATE OF IDAHO
PERMIT TO CONSTRUCT AN
AIR POLLUTION EMITTING SOURCE
1. PERMITTEE
Valley Paving and Asphalt Tnc.
2. PROJECT
Asphalt
3. MAILING ADDRESS
P.O. Box 57
.TITLE
Owner
CITY
Cottonwood
6. EXACT PLAINT LOCATION
34 mile NE of intersection of Boydstun Street and Chad Drive.
(OR) SW 14 NW 34, Section 17, Township 18N, .Range 3E
7• GENERAL NATURE OF BUSINESS AND KINDS OF PRODUCTS
Asphalt Plant/ Asphaltic Concrete Manufacturing
GENERAL CONDITIONS
This permit is issued according to the Rules and Regulations for the Control
of Air Pollution in Idaho, Section 16.01.01012
of air contaminants which are regulatedand Pertains only to emissions
specifically allowed to be constructed by this permit°f Idaho and to the sources
This permit (a) does not -.affect the title of the premises upon which the
equipment is to be located, (b) does not release the
liability for any loss due to damage to person or proppe�Ytcaused b any
from, or arising out of the design, installation,.maintenance, or operation
of the proposed'equiPment ) Y. resulting
with other a • (c does not release the permittee from compliance
or
ordinances, pplioable federal, state, tribal of local laws, regulations,
and Welfare, or itsno manner officers, agents,lies oorsuggests that the Department of Health
directly or indirectly, for any loss due to damage to person or
by, resultinges any liability,
operation of the m, or arising out of design, installation Property caused
ed equipment. maintenance, or
This permit is not transferable to
ire another person, place, piece or set of
equipment. This permit will ex , of its issue date or if constructionlisconstructsusp ndedoforaoneoyear.
gun within two years
THIS PERMIT HAS BEEN GRANTED ON ITS APPLICATION. CHANGES OF DESIGN OR
IIN ANY SCH PRESENTED
IN
THE NATURE OR AMOK THE DEPARTMENT.
OF EMISSIONS MUST BE APPROVED IN ADVANCE BY
� TMENT.
J. OE 20
i
DATE: June 10, 1993
p Z)
" P a g e 2 o f 1 0
��1
; ,
P E R M I T T O C O N S T R U C T
P E R M I T T E E , P R O J E C T , A N D L O C A T I O N
V a l l e y P a v i n g & A s p h a l t I n c .
P o r t a b l e A s p h a l t P l a n t
I d a h o
S O U R C E
P E R M I T N U M B E R
7
7
7
0
0
0
8
6
H a u c k M a n u f a c t u r i n g 2 0 0 t o n / h r H o t - M i x A s p h a l t P l a n t
1 . S O U R C E D E S C R I P T I O N
1 . 1 P r o c e s s D e s c r i p t i o n
A g g r e g a t e , s a n d , a n d a s p h a l t c h i p s a r e t r a n s p o r t e d o n s i t e b y t r u c k
a n d p l a c e d i n p i l e s n e a r t h e a s p h a l t p l a n t . A g g r e g a t e i s l o a d e d
v i a a f r o n t - e n d l o a d e r i n t o a 3 - b i n h o p p e r . T h i s h o p p e r f e e d s
a g g r e g a t e , s a n d , a n d a s p h a l t c h i p s t o a s u b s e q u e n t c o n v e y o r b e l t .
T h e c o n v e y o r f e e d s t h e b u r n e r e n d o f t h e 7 0 m m B T U p e r h o u r , N o . 2
f u e l o i l - f i r e d d r u m m i x e r . H e a t e d a s p h a l t o i l f r o m a 1 5 , 0 0 0 g a l l o n
p o r t a b l e s t o r a g e t a n k i s i n t r o d u c e d a t t h e m i d d l e o f . t h e d r u m u n i t ,
w h e r e i t m i x e s w i t h t h e r a w a g g r e g a t e . T h e p r o d u c t i s t h e n
c o n v e y e d t o a s t o r a g e s i l o v i a ' a n e n c l o s e d s l a t c o n v e y o r . F r o m t h e
s i l o , t h e p r o d u c t i s t r a n s f e r r e d b y g r a v i t y f l o w t o h a u l t r u c k s
w h i c h t r a n s p o r t t h e m a t e r i a l o f f s i t e .
1 . 2 C o n t r o l D e s c r i p t i o n
E m i s s i o n s f r o m t h e a s p h a l t d r u m m i x e r a r e v e n t e d t o a v e n t u r i
s c r u b b e r b e f o r e b e i n g e m i t t e d t o t h e a t m o s p h e r e , a n d o p e r a t e s w i t h
a w a t e r f l o w r a t e o f 6 0 t o 1 4 0 g a l l o n s p e r m i n u t e a n d a p r e s s u r e
d r o p o f 1 2 t o 1 5 i n c h e s o f w a t e r . T h e e s t i m a t e d c o l l e c t i o n
e f f i c i e n c y o f t h e s c r u b b e r i s 9 8 p e r c e n t f o r c o n t r o l o f p a r t i c u l a t e
m a t t e r .
1 . 3 E q u i p m e n t S p e c i f i c a t i o n s
1 . 3 . 1 A g g r e g a t e a n d A s p h a l t C o n c r e t e H a n d l i n g S y s t e m s
A g g r e g a t e , s a n d , a n d a s p h a l t c h i p b i n
U n e h c l o s e d a g g r e g a t e f e e d c o n v e y o r s
A g g r e g a t e w e i g h c o n v e y o r
E n c l o s e d a s p h a l t c o n c r e t e s l a t c o n v e y o r
A s p h a l t c o n c r e t e s i l o / s u r g e h o p p e r
1 . 3 . 2 P o r t a b l e D r u m - M i x A s p h a l t P l a n t
M o d e l - - H a u c k M a n u f a c t u r i n g H o t M i x D r u m , M o d e l S J 3 6 0 ,
f i r e d b y N o . 2 f u e l o i l .
4 1 /
A S S I S T A N T B D M I N I S T R A T O R
P E R M I T S A N D E N F O R C E '
D A T E : J u n e 1 0 , 1 9 9 3
IDAHO DEPARTMENT
OF HEALTH AND WELFARE
DIVISION OF
ENVIRONMENTAL QUALITY
1410 North Hilton, Statehouse Mall, Boise, ID 83720-9000, (208) 334-0502 Cecil D. Andrus, Governor
June 10, 1993
MEMORANDUM
TO: Martin Bauer, Chief
Construction Permits Bureau
f.
FROM: Darrin Mehr /1/1 � 1.%.
Air Quality Engineer
Operating Permits Bureau
SUBJECT: Permit to Construct Technical Analysis
Valley Paving (McCall) -- P-930502 (Asphalt Plant)
I. Purpose
The purpose for this memorandum is to satisfy the requirements of
IDAPA 16.01.01012 (Rules and Regulations for the Control of Air
Pollution in Idaho) for issuing Permits to Construct.
II. Project Description
Valley Paving proposes to construct a Hauck Manufacturing 200 ton
per hour drum mix asphalt plant equipped with an AESCO venturi
scrubber. The asphalt plant will burn No. 2 distillate fuel oil in
the drum. The following items were investigated prior to issuance
of the permit:
A. Area Classification. Valley Paving is a portable source
to be initially located in McCall, Idaho. McCall is an
attainment area.
B. Emission Estimates. The emissions are estimated from
this plant using AP-42 , Table 8.1-3 , Table 8.1-4 , and the
federal standard of 0.04 grains per dry standard cubic
feet. Appendix A presents the calculations.
C. Facility Classification. The facility is not a
designated facility, as defined in IDAPA 16.01.01003,27
{Rules and Regulations for the Control of Air Pollution
in Idaho). The facility is not a major facility as
defined in IDAPA 16.01.01003,54.a.
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